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BaylorUniversity Institute for Air Science Aviation Science Program

One BearPlace #97413 Waco, TX 76798-7413 

### PETITION FOREXEMPTION . - , .• I- ,-

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28 April2014 U.S. Department ofTransportation DocketManagement System 400 7th Street, SW. RoomPL401 Washington, DC 20591-0001 SUBJECT: PETITIONFORGRANT OF EXEMPTION Pursuantto Section 11.25 ofthe Federal Aviation Regulation (FAR), BaylorUniversity's Aviation Science Program, housed within the Baylor Institute for Air Science, hereby petitions the Federal Aviation Administration (FAA) for exemption from 14 CFR 61.160(b) to the extent necessary to permit BaylorUniversity to issue a letter ofauthorization certifying its graduates for an Airline Transport Pilot Certificate with reduced aeronautical experience. NATURE AND EXTENT OF RELIEF Certifying graduating students who have earned the Bachelor ofScience in Aeronautical Science (B.S.A.S.) degree for an Airline Transport Pilot Certificate with reduced aeronautical experience will require exemption to 14 CFR 61.160(b). FAR §61.160(b) states, in pertinent part: "Aperson may apply for an airline transportpilot certificate with an airplane category multiengine class rating or an airline transport pilot certificate concurrently with an airplane type rating with a minimum of 1,000 hours oftotal time as a pilot ifthe person: (1) Holds a Bachelor's degree with an aviation major from an institution ofhigher education, as defined in §61.1, that has been issued a letter ofauthorization bythe Administrator under §61.169; (2) Completes 60 semester credithours ofaviation and aviation-related courseworkthat has been recognized bythe Administrator as coursework designed to improve and enhance the knowledge and skills ofa person seeking a career as a professional pilot; (3) Holds a commercial pilot certificate with an airplane category and instrument rating if:(i) The required ground training was completed as part ofan approved part 141 curriculum atthe institution ofhigher education
..." This reliefis requested in orderto allow BaylorUniversityto certify its graduates for an Airline Transport Pilot Certificate with reduced aeronautical experience, specifically due to the fact thatthe required ground and flight training, leading to the Instrument Pilot Rating and the Commercial Pilot Certificate, are all conducted viaFAA approved Training Course Outlines (TCO's) attached to Part 141 Certificate Number FT8Sl50Q, maintained by Texas State Technical College. Furthermore, TSTC has recently been awarded a letter ofauthorization to certify its graduates for an airline transport pilot certificate with reduced aeronautical experience.
PUBLIC INTEREST Granting ofthis petition for exemption to permit BaylorUniversity to certify its graduates for an Airline Transport Pilot Certificate with reduced aeronautical experience is in the public interest for reasons of economy ofresources, cost effectiveness for the student, and synergy with the student's flight training experience. IfBaylorwere to teach the Part 141 ground school courses for our curriculum, we would essentially be duplicating the efforts ofTSTC'sPart 141 ground school course (which our students currentlytake). This would mean duplicating manpower and instructional time beyond what is currently required. The courses at Baylorwould also be more expensive than the courses at TSTC (since Baylor tuition is much higherthan TSTC's), effectively increasingthe cost ofthe degree for our students. Finally, TSTC's ground school courses are designed to work in tandem with their flight courses to provide their students an integrated curriculum experience. That synergy would be broken ifBaylor is teachingthe ground school courses while the flight courses aretaught atTSTC. EQUIVALENT LEVEL OF SAFETY Consideringthe fact that ground and flight education requirements under question are provided by Texas State Technical College (TSTC), Part 141 CertificateNumberFT8S150Q, the level ofsafety is at least equivalent. The following courses, both flight and ground, are the courses that were considered by the FAA inthe recent 8700-1 applicationthat led to a letter ofauthority being awarded to TSTC. Part 141 Flight Courses and Course Descriptions AIRP 2250 Instrument Pilot Flight Preparation for completion ofthe Federal Aviation Administration InstrumentPilot rating with mastery ofall instrument procedures. AIRP 2239 Commercial PilotFlight Flight instruction necessaryto qualify for the Federal Aviation Administration Commercial Pilot Certificate. Instruction includes both dual and solo flight trainingto prepare the student for mastery ofall commercial pilot maneuvers. Part 141 GroundCourses andCourse Descriptions
AIRP 1451 InstrumentPilot Ground SchoolA study ofbasic instrumentradio and navigation fundamentals used in instrument flight. Topics include a description and practical use ofnavigation systems and instruments, charts used for instrument flight, and Federal Aviation Administration regulations. Qualifies as part ofa program leading to Federal Aviation Administration certification. AIRP 2337 Commercial Pilot Ground School A study ofadvanced aviation topics that can be used for federal aviation administration certification atthe commercial pilot level. Includes preparation for the commercial airplane written test.
It is important to note thatBaylor students who complete these courses do so at TSTC, on the TSTC campus, taught by TSTC faculty members in TSTC classrooms and in TSTC aircraft. The Baylor students are also required to submit applicationto TSTC and be accepted into TSTC. Grades are awarded at TSTC and officially recorded on TSTC transcripts
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. Additional Courses Taught atBaylor UniversityPossessingSafetyRelatedContent

Arguably, the additional safety related courseworkthat is completed by a Baylor graduate provides additional levels or layers ofsafety insight, safety awareness, and an overall safety-first mindset. Examples ofcourses which are heavily laden with safety topics include, but are not limited to: AVS 3311 Aircraft Accident Investigation and Prevention A comprehensive overview ofthe procedures and methods used and the skills required to investigate an aircraft accident with emphasis placed on accident prevention. AVS 3315 Advanced Aviation Meteorology Physical and chemical processes in the atmosphere which affect aviation including atmospheric motion, climatic conditions, and pollution. Weather map analysis and forecasts. AVS 3320 Aviation Operations Airline, corporate, and military flight operations with emphasis placed on daily operational environments. AVS 4305 CrewResource Management A study ofcognitive processingtheory, organizational behavior, interpersonal relationship. skills, and other critical behavioral dynamics ofprofessional flight crews. Specific CRM topics to be studied include information processing, human error, human reliability, error management, fatigue and workload management, situational awareness, CRMphase development, and CRM specific federal regulations as they pertain to aviation.
The added depth and scope ofcoursework completedby Baylor students in addition to the existing Part 141 ground and flight training curriculum administered at TSTC warrant granting the requested ability to reduce the graduate's required aeronautical experience. SUMMARY As required by FAR Section 11.25(d), a summary ofthe petition is as follows:Baylor University's Aviation Science Program housed within the BaylorInstitute for Air Science requests an exemption from FAR Section 61.160(b) to grant BaylorUniversity authority to certify its graduates for an Airline Transport Pilot Certificate with reduced aeronautical experience.

Sincerely,

Timothy James Compton AssistantDirector Institute for Air Science BaylorUniversity